The FTC has reiterated that unfair or deceptive practices can arise from failures to honour data use, security, and retention commitments made in contracts and privacy disclosures. In FTC v Wyndham Worldwide Corporation, the court confirmed that inadequate cybersecurity practices may constitute unfair practices under Section 5 of the FTC Act. For scaling technology companies, vendor agreements, data sharing terms, and internal policies must align precisely, as contractual overreach or under-delivery can directly trigger regulatory exposure.